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FDIC pass-through insurance alternative record-keeping

FDIC Rule 370 requires that large depository institutions be able to accurately calculate FDIC insurance coverage for all depositors in the event of failure. In most instances, Santander Bank ("Santander") has the necessary records to fulfill this requirement through automated processes. In some cases, however, Santander does not have information for the insured beneficial owners of funds deposited within third-party accounts, where FDIC insurance "passes through" our Santander customer to a third party. In the event of failure, insured deposits for third-party accounts cannot be released to direct customers until Santander receives the missing data and completes insurance calculations. For this reason, the FDIC offers the option of alternative record-keeping to allow third-party account holders to submit this information only as needed—if, and when, failure occurs.

Alternative record-keeping allows third-party fund owners to electronically submit necessary information to expedite an insurance determination. By this method, files are only submitted in the event of failure, based on requirements outlined in the FDIC Deposit Brokers Processing Guide

Submission directly to FDIC

All third-party account holders storing funds owner data are eligible to submit a file to the FDIC, in lieu of Santander doing so, irrespective of whether such third-party account owners are deposit brokers or not. Files may be submitted by mail to the FDIC directly at the address at right however, this manual processing may result in a lengthier deposit insurance determination.

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Federal Deposit Insurance Corporation

Attention: Shelia Lollie
600 north Pearl Street, Suite 700
Dallas, TX 75201

FDIC transmission

Santander has developed an ad hoc transmission process for third-party pass-through account holders or servicers to submit alternative record-keeping files in the unlikely event the bank is placed into receivership by the FDIC. This process is kept simple to minimize processing delays. In the event of bank failure, Santander customers could obtain credentials to use our secure transmission portal, called Intralinks, to submit owner data within 24 hours of Santander failure. 

Submitting an ad hoc transmission

In the event of a Santander failure, follow the below instructions. Santander welcomes owners of any account-holding third-party customer funds to test this transmission functionality by executing the same below. For more information on submitting a test file, please send an email to

Follow these 3 steps

Send an email to requesting access to our portal (Intralinks) to submit an alternative record-keeping file. Include the following in your request:
  • Subject line of email must read “ARE Portal Access Request” 
  • Customer entity name
  • Customer entity phone number 
  • Customer entity address 
  • Primary customer contact name, email, and phone number
  • Customer alternate contact (name, email, and phone number if applicable)

You will receive an email from Intralinks with instructions on how to activate your account so your file(s) can be submitted.

The FDIC requires an ASCII flat, tab-delimited file, which is a text file with extension. Please leverage the "ARE_Submission Template_v1" provided below as a Microsoft Excel file for this purpose; the file consists of columns with header records. The columns follow the prescribed FDIC broker submission format, followed by 10 Addendum Fields, with a few Santander-specific columns. All columns highlighted in grey are required fields for submission.

red icon of a downward facing arrow in a circleDownload_ARE_Submission Template_v2.xlsx

After populating the file with the required information, take the following steps to ensure your file is in the correct format:

  • Save as a tab-delimited text file (.txt) using the following naming format:
    NOTE: Your customer name should be all lowercase and sequence starts with 1 and ascends with each additional file. For example: abccompany_20230101_v1_data.txt

When creating this alternative record-keeping file, please note the following:

  • Unique Identifier Permissible: FDIC guidance indicates the "customer account number" field is optional. This field is required by Santander and allows you to assign a unique identifier to each account in the file for easier reconciliation.
  • If an account holder owns any balances in the account for which the file is being submitted, the account holder must include their own entity information in the alternative record-keeping file to identify those balances—in order to distinguish them from funds owned by the account owner's third-party customers.
  • Ownership Rights & Capacity (ORC): This is a required field. you can use the following chart to determine the applicable ORC code. View ORC Chart.
After receiving access to Intralinks, you will receive an automated email inviting you to set up your account and upload
documentation for the Ad-Hoc FDIC Transmission. 

Santander will review documentation and reach out through email if we identify any errors in the file that would prevent it
from processing properly.

Still have questions? We’re here to help.

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Type of ORC
ORC Code
Simple Desciption
FDIC Description
A single account is a deposit owned by a single natural person.
A joint account is a deposit owned by two or more people. FDIC insurance covers joint accounts owned in any manner conforming to applicable state law, such as joint tenants with right of survivorship, tenants by the entirety, and tenants in common.
Revocable Trust Accounts
A revocable trust account is a deposit account owned by one or more people that identifies one or more beneficiaries who will receive the deposits upon the death of the owner(s). A revocable trust can be revoked, terminated, or changed at any time, at the discretion of the owner(s). In this section, the term “owner” means the grantor, settlor, or trustor of the revocable trust.
Irrevocable Trust Account
Irrevocable trust accounts are deposit accounts held in connection with a trust established by statute or a written trust agreement in which the owner (also referred to as a grantor, settlor, or trustor) contributes deposits or other property to the trust and gives up all power to cancel or change the trust. An irrevocable trust also may come into existence upon the death of an owner of a revocable trust.
Certain Retirement Account
Certain retirement accounts are self directed retirement deposits for which an owner and not a plan administrator has the right to direct how the funds are invested. (Individual Retirement Account (IRA), Self-directed defined contribution plan account, Self-directed Keogh plan account (or ¾.R.H0 plan account) designed for self-employed individuals, All Section }[7 deferred compensation plan accounts)

Government Accounts

Government accounts are also known as public unit accounts. This category includes accounts of the federal government, state governments, and other governmental bodies.
Business/Organization Accounts
Deposits owned by corporations, partnerships, and unincorporated associations, including for-profit and not-for-profit organizations.
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